Independent of the business model that information destruction professionals select for their operations, certain environmental and safety considerations are required when handling electronic devices. Primarily, "What comes in, must go out." That means, if a piece of electronic equipment has a circuit board, it has toxic material. The Resource Conservation and Recovery Act (RCRA), which gives the Environmental Protection Agency the authority to control hazardous waste from the "cradle-to-grave," including generation, transportation, treatment, storage and disposal, is not heavily enforced. However, if a company should get caught in violation of the RCRA, the fines are expensive.
Because of the potential toxicity of some components, special handling techniques should be adhered to and workers should have adequate personal protection equipment.
Also, the liability for mishandling customer data is potentially very great. Just as with paper documents, once you take possession of these devices, you are responsible for safeguarding them. Electronic media and devices are also easier to steal, easily fitting in a pocket, and contain great volumes of information.
Finally, there are logistics issues to consider. Electronic devices are heavy and do not ship conveniently or easily.
After considering these liability issues, an information destruction professional can enter the electronics recycling realm in a number of ways.
OPPORTUNITIES IN E-DESTRUCTION
Some document destruction professionals enter the business passively, in that they are not really marketing IT destruction services, but are asked by their existing customers to handle their IT equipment or electronic storage devices. In some cases, these document destruction companies are not really interested in handling electronics, but they don’t want to risk losing a customer or allowing a competitor to get a foothold in their accounts.
Protecting their accounts is a considerable motivating factor, because document destruction companies are not the only firms exploring adding services. Computer recyclers are looking into adding document destruction services, and waste haulers are exploring adding e-destruction services and document destruction services.
Other document destruction professionals are actively looking for opportunities in electronics recycling or electronic media destruction. They have made a conscious decision to provide e-destruction services to existing and new customers or are responding to a competitor’s foray into this segment.
Also, a key customer could request e-destruction services, creating an opportunity for the document destruction firm that warrants the expenditure of capital and the diversion of resources to make it happen.
Among the questions to ask yourself if you are considering handling e-destruction services are:
1."Will I focus on security in the e-destruction services I provide?" While this is a no-brainer, it is worthy of mention. Many companies get into the business for the back-end revenue off the equipment, which makes the business difficult to sustain in light of its low margins and commodity-driven nature. This model could sometimes force decisions that compromise customer security.
2."Will I perform the services myself or will I use a third-party vendor/partner for all or part of this endeavor?" Partners/vendors allow for quicker and easier entry into the market and give you an opportunity to "try before you buy." However, problems could arise if the relationship does not work out.
It’s important not to dabble in information technology asset management
Protecting confidential information is one of many issues with which electronics recyclers must be concerned. Speakers at a session titled "Keep It Confidential" during the Recycling Today Media Group’s inaugural Electronics Recycling Conference & Trade Show discussed the various data protection laws governing data security and available information destruction methods. Bob Johnson, executive director of the National Association for Information Destruction, described the electronics recycling industry as "the Wild West," saying that "opportunists" can capitalize on the confusion that exists in the marketplace. Johnson discussed legislation governing data protection, including the Health Insurance Portability and Accountability Act, the Financial Services Modernization Act (also known as Graham-Leach-Bliley) and the Economic Espionage Act, which call for entities to take reasonable measures to prevent unauthorized access to data. He said 13 states currently have laws with information destruction requirements, with only one differentiating between electronic and paper documents. These laws have also led to prosecutions, including six in Texas and 10 in Georgia. Mick Schum, president of WeRecycle!, based in Wallingford, Conn., provided information on the various methods of information destruction, from the virtual to the physical. Electronics recyclers can employ deformation, pulverizing, degaussing, overwriting and shredding to destroy information saved to a hard drive. However, Schum warned that data can be obtained from large sections of the platter of a deformed hard drive. He also said that screens are particularly important when shredding hard drives, as they ensure an acceptable particle size. While degaussing is a physical form of destruction using a strong magnetic field that works for digital media and renders hard drives unusable, it is not a visual form of destruction and can leave room for human error, Schum cautioned. Data overwriting enables hard drives to be reused. Using overwriting software, every track and sector of the hard drive is overwritten with a predefined pattern of random data, Schum said. Department of Defense (DoD) 5220.22-M Directive is the industry recognized standard, he added, and it is satisfactory up to "secret" level clearance. Data overwriting software requires three overwrite passes of each sector and verification of the process. Peter Prinz of American Electronics Recycling (AER), Sarasota, Fla., said AER used to wipe all hard drives to DoD 5220.22-M specifications. Now, however, AER’s preferred method for data protection is hard drive destruction. AER puts sensitive or classified hard drives into boxes that are then sealed and marked. The hard drives are shredded without being removed from these containers, eliminating human error that can occur with data overwriting, according to Prinz. The Electronics Recycling Conference & Trade Show was at the Peabody Hotel in Orlando, Fla., June 10 to June 12. The World Reuse, Repair and Recycling Association, Middlebury, Vt., planned the programming. –DeAnne Toto
(ITAM). The stakes are just too high and could result in regulatory fines and civil suits as well as distract you from your core competencies. Poor performance in this sector will also reflect poorly on your core competencies, resulting in tarnished referrals and unhappy employees, which could lead to the loss of key personnel.
PRIVACY MATTERS
However, for those document destruction firms that decide to pursue e-destruction opportunities, a variety of business models exist.
POTENTIAL BUSINESS MODELSA variety of business models for ITAM exist that document destruction firms can use alone or in combination.
Finder’s-Fee Model – In this model, a document destruction firm identifies a partner or vendor to work with and performs serious due diligence, working only with a partner who meets or exceeds the NAID Certification Standard. Additionally, you should only work with a partner that is willing to sign non-compete and non-disclosure agreements. The non-disclosure agreement must cover the customer data the company is handling and the nature of your deal with the company. The non-compete agreement should preclude your partner from working in the account for an agreed upon length of time and cover all the services you currently provide to the customer.Such an arrangement benefits a document destruction firm because it entails few out-of-pocket expenses apart from those associated with due diligence and legal fees for the non-disclosure and non-compete agreements. These agreements are also easy to manage and allow you to keep control of your customer and account.
However, the limitations include being at the mercy of your partner’s time frame, culture and philosophies; enforcing non-compete and non-disclosure agreements; and, finally, if your partner performs poorly, it will reflect poorly on your company.
Limited Hard Drive Destruction Model – In this model, you destroy only hard drives. You do not handle the rest of the computer and instead use a finder’s-fee model or simply refer your customer to someone else. You inventory all hard drives prior to destruction, enact systems to perform barcoded inventory reporting and quality control on your destruction process.This model creates an additional revenue stream that aligns well with your core competency of document destruction, allows you to maintain a position of expertise and to be a full-service provider for your customer’s information and you potentially possess all of the equipment you need to destroy hard drives.
Limitations associated with this business model include having to invest in personnel, equipment and technology to perform the service effectively and reliably; disposing of the waste properly could represent a cost to you if the volumes are insufficient to interest a commodities buyer; state or local permitting may be required to destroy or process this material; and existing equipment could be damage or excessively warn or incur higher maintenance costs. Additionally, flammable material in hard drives could present a fire hazard if sparks ignite paper particles or dust.
Variations on the limited destruction model include disabling and shredding or otherwise completely destroying the hard drives. To disable the hard drives, you damage them by extreme physical force to their platters, such that the connections to the drives are mangled. This is an intermediary step before a third party performs the ultimate disposition by smelting or shredding the drives.
I do not rely on degaussing to damage the hard drives. I find it is nearly impossible to easily and cost effectively verify the destruction of the drives and requires specific expensive equipment and specially trained technicians to operate and calibrate it.
Asset Management Model – In this model, you evaluate your customers’ equipment and required services, pay them for their good equipment, charge them to recycle the unusable equipment and supply security services, such as hard drive destruction, hard drive wiping, inventory reports, etc.The benefits associated with this model, in addition to maintaining complete control of your customer, are higher potential and bi-directional revenue and the ability to offer customers a solution that may not be strictly a cost to them but that might offer revenue back.
The limitations to this model are the daily/hourly margin reduction (18 percent to 36 percent per quarter), the introduction of new technology makes some devices worthless over night, it requires a high level of in-house expertise in computer hardware and computer resale market values and you can get quickly burned on equipment promised that is not delivered in a timely fashion. For example, a contract is signed Jan. 1 with pricing based on the fair market value as of Dec. 31. The customer drags its feet and doesn’t release the equipment until April 1. In the meantime, Dell comes out with a new special. While you originally projected making $100 per unit, now you will end up taking a loss on each unit.
When offering e-destruction services, you should not count on the backend revenue from equipment resale; you will go broke. You have to spend a lot of time with your clients getting detailed specifications of their equipment. No matter how good the equipment is, there will always be bad stuff that is pure cost. The biggest clients’ equipment will have the most value, since smaller businesses hold onto their equipment until it has no value left. The resale of equipment requires volume, volume, volume (thousands of like pieces at a minimum). Onsie, twosie retail sales via Ebay are low margin, labor intensive and customer service intensive.
Physical Computer Destruction Model (without monitors) – Identify a shredder manufacturer and a consumer for the shredded by-product. Know your customer sources and the volumes they are capable of generating as well as the government regulations for your area.The benefits to this model include assurance of complete destruction, no third party to deal with your customer base, less environmental liability and upfront costs than when dealing with monitors and reduced labor costs.
The limitations associated with this model are purchasing expensive shredding equipment, commingled by-products that must be properly managed, risk of losing customers to a vendor that can process monitors and the extreme volume needed to produce a return on investment.
Complete Physical Computer Destruction Model – This model involves identifying equipment manufacturer(s) that have the capability to separate and process multiple material streams, including hazardous materials, and environmentally safe processes. It also involves identifying consumers for shredded by-products and a partner to process hazardous waste. This model requires knowing your customer sources and the volumes they are capable of generating and the government regulations for your area.The benefits of such a model include assurance of complete destruction and environmental compliance, no third party dealing with your customer base, providing a "one-stop shop," the ability to partner with or act as a vendor to other destruction companies, a reduction in labor costs and risk reduction for your customers.
Limitations associated with this approach include the expense of shredding, separation and filtration management; the need to generate very high volumes of separated by-products to make a profit; the potential for customers that want end-of-life asset management; and the extreme volume needed to produce a return on your investment.
PARTNERSHIP DOS AND DON’TSFor those destruction firms who opt for the partnership model, I suggest you do the following prior to finalizing a partnership agreement:
• Do perform extensive due diligence on your partner.
• Do visit the facilities that will process your material.
• Do insist on prices, revenue shares and finders fees upfront.
• Do insist on non-compete agreements and non-disclosure agreements.
• Do spend the time and money to verify all of your potential partner’s references.
• Do try to work with partners that are active members of NAID.
• Don’t work with anyone whose security standards do not meet or exceed your own.
• Don’t share any client information until signed agreements are in place with a vendor.
• Don’t work with anyone who doesn’t carry pollution liability and errors and omissions insurance coverage.
• Don’t permit any material that you send to a partner to be sent to a landfill.
• Don’t permit any material that you send to a partner to be processed within the prison system.
I hope these guidelines will help you form a beneficial partnership, should you decide that’s the best business option for your business.
The author is president of corporate security and compliance for Tyron, Pa.-based Reclamere Inc. She can be reached at angie@reclamere.com.
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